Epstein Secrets

o. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp. 2d 1203 (C.D. Cal. 1999) 7 iii EFTA00065719 Statutes 18 U.S.C.

inly arise." Stephens, 447 F. Supp. 3d at 65. We urge the Court to weigh the threat of COVID as a factor favoring release in this case, as it did in Stephens. CONCLUSION Ghislaine Maxwell is committed to defending herself and wants nothing more than to remain in this country, with her family and friends

15 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 8 United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp.

o. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp. 2d 1203 (C.D. Cal. 1999) 7 iii EFTA00154515 Statutes 18 U.S.C.

inly arise." Stephens, 447 F. Supp. 3d at 65. We urge the Court to weigh the threat of COVID as a factor favoring release in this case, as it did in Stephens. CONCLUSION Ghislaine Maxwell is committed to defending herself and wants nothing more than to remain in this country, with her family and friends

15 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 8 United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp.

o. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp. 2d 1203 (C.D. Cal. 1999) 7 iii EFTA00094292 Statutes 18 U.S.C.

inly arise." Stephens, 447 F. Supp. 3d at 65. We urge the Court to weigh the threat of COVID as a factor favoring release in this case, as it did in Stephens. CONCLUSION Ghislaine Maxwell is committed to defending herself and wants nothing more than to remain in this country, with her family and friends

15 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 8 United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp.

al under the current pandemic situation is just not realistic. It is not meaningful. It is not fair. And I should say, as your Honor noted, in the Stephens case, we are not faulting the Bureau of Prisons. We are not faulting the Marshal Service. We understand they are doing the best they can under the

limits in the early instances your access to the client. It is complicated by the COVID crisis and the other factors your Honor has pointed out in Stephens and in Williams-Bethea, and so it is very hard for us to pull together this financial information, and we have done it as quickly as we could befor

15 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 8 United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp.

on documents) with Ms. Maxwell and will further compromise her ability to prepare her defense. Moreover, as this Court observed in United States v. Stephens, if an outbreak occurs "substantial medical and security challenges would almost certainly arise." Stephens, 447 F. Supp. 3d at 65. We urge the Cour

inly arise." Stephens, 447 F. Supp. 3d at 65. We urge the Court to weigh the threat of COVID as a factor favoring release in this case, as it did in Stephens. CONCLUSION Ghislaine Maxwell is committed to defending herself and wants nothing more than to remain in this country, with her family and friends

of extradition" as a condition 26 EFTA00093247 C6geel.20-ThinKINAlltilit Medititl 2FriJ 01724/2Bardgel 31 35 45 of release); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004) (ordering each of two defendants to "execute and file with the Clerk of the Court a waiver of extradition